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CAMBRIDGE RESEARCH AND DEVELOPMENT GROUP v. COMMISSIONER

Docket No. 3435-88.

97 T.C. 287 (1991)

CAMBRIDGE RESEARCH AND DEVELOPMENT GROUP, KENNETH N. SHERMAN, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 5, 1991.

Attorney(s) appearing for the Case

Geoffrey J. O'Connor, for the petitioner.

Joseph F. Long, for the respondent.

OPINION

HALPERN, Judge:*

In T.C. Memo. 1989-679 (Cambridge I), we denied petitioner's motion to dismiss for lack of jurisdiction on the grounds that petitioner's claim with regard to the statute of limitations did not present a jurisdictional issue but, rather, raised a defense in bar. Subsequently, the parties jointly moved that petitioner's defense in bar be separated from any other...

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